RE: The country of origin of a broom

U.S. Department of Homeland Security U.S. Customs and Border Protection National Commodity Specialist Division One World Trade Center, Suite 51.201 New York, NY 10007 U.S. Customs and Border Protection N364454 September 3, 2026 OT:RR:NC:N4:462 CATEGORY: Origin Steve Law Charles Bentley & Son Limited 1 Monarch Way Loughborough, Leicestershire LE11 5TP United Kingdom RE: The country of origin of a broom Dear Mr. Law, In your letter dated August 21, 2026, you requested a country of origin ruling on a broom. Product images were submitted in lieu of samples. The product under consideration is described as a heavy-duty, mixed-fill sweeping broom designed for industrial, commercial, and domestic sweeping applications. Per the submitted images, it is a push broom featuring a wide head with a handle that measures approximately 47 inches in length. The broom is available in six SKUs, with heads that range from 11 inches to 18 inches in width. While the manufacturing process and materials are the same for all variants, the ratio of natural to synthetic fiber bristles may vary depending on the SKU. The broom consists of a wooden head made from timber block sourced from Sri Lanka, bristles made of natural bassine/palmyra fiber from India and synthetic polyethylene terephthalate (PET) fiber from Italy, a plastic bracket, metal handle, and metal scraper all sourced from China, and metal staple wire from France. In your submission, you outline a manufacturing scenario in which all components are shipped to the United Kingdom. In the United Kingdom, holes are precision drilled into the timber block and filled with a combination of natural bassine fiber and PET synthetic fiber which are permanently secured into the timber block using wire staples. The filled broom head is trimmed, dressed, and inspected to achieve the required sweeping profile and manufacturing specification. The plastic socket is attached, the metal handle and metal scraper are fitted, and the completed broom is inspected before packaging for export from the United Kingdom. When determining the country of origin, the substantial transformation analysis is applicable. See Headquarters Ruling Letter (“HQ”) H301619, dated November 6, 2018. The test for determining whether a substantial transformation will occur is whether an article emerges from a process with a new name,
character, or use different from that possessed by the article prior to processing. See Texas Instruments Inc. v. United States, 681 F.2d 778 (C.C.P.A. 1982). This determination is based on the totality of the evidence. See National Hand Tool Corp. v. United States, 16 CIT 308 (1992), aff’d, 989 F.2d 1201 (Fed. Cir. 1993). You suggest the country of origin for the broom is the United Kingdom. We agree. Customs has previously determined the broom head to be the essence of a finished broom. See HQ 733804, dated November 9, 1990. The handle, while necessary for a broom to be functional, is not the essential element of the finished article. Accordingly, the country of origin of the finished broom is the country where the broom head was made. Based on the facts you have submitted regarding the production of the broom head in the United Kingdom, such operations have effected a substantial transformation, resulting in a new name, character and use of the non-originating components. Thus, the country of origin of the broom head, and therefore of the finished broom, is the United Kingdom. The holding set forth above applies only to the specific factual situation and merchandise description as identified in the ruling request. This position is clearly set forth in Title 19, Code of Federal Regulations (CFR), Section 177.9(b)(1). This section states that a ruling letter is issued on the assumption that all of the information furnished in the ruling letter, whether directly, by reference, or by implication, is accurate and complete in every material respect. In the event that the facts are modified in any way, or if the goods do not conform to these facts at time of importation, you should bring this to the attention of U.S. Customs and Border Protection (CBP) and submit a request for a new ruling in accordance with 19 CFR 177.2. Additionally, we note that the material facts described in the foregoing ruling may be subject to periodic verification by CBP. This ruling is being issued under the provisions of Part 177 of the Customs and Border Protection Regulations (19 CFR 177). A copy of the ruling or the control number indicated above should be provided with the entry documents filed at the time this merchandise is imported. If you have any questions regarding the ruling, please contact National Import Specialist Sandra Walia at [email protected]. Sincerely, (for) James P. Forkan Director National Commodity Specialist Division